Concernsincludeunderground and other alternatives; purpose and need; greenhouse gas emissions and environmental impacts of power sources; visual impacts; impacts on conservation land and WMNF; procedural fairness and impartiality.

Concerns include procedural fairness and impartiality; purpose and need defined too narrowly to the unfair benefit of applicant; lack of alternative routes, sites, designs and analysis of their impacts. Calls for comprehensive analysis of impacts of generation and transmission in Canada and environmental (including visual) impacts in U.S. AMC renews its request for post-scoping pre-draft EIS to be circulated.

Shortcomings of National Wetland Inventory require applicant to collect on the ground data and make it available to the public. The project must meet highest environmental standards during construction and ongoing maintenance.

Alternatives, including non-transmission, burial, and routes in other states, must be considered. More rigorous analysis of GHG emissions of hydro dams is necessary.Mistaken approaches used for EIS of Champlain Hudson project must not be repeated for Northern Pass. Assess environmental impacts in Canada in light of Northern Pass's claims. Ongoing procedural deficiencies and renewed call for changes in DOE NEPA process.

"We are concerned that the project will increase the risk of loon power line collisions. Loons are particularly vulnerable to these collisions because they are large, heavy-bodied birds and maneuver poorly in flight.. . [L]oons, with vision adapted for underwater foraging, may have trouble seeing and avoiding power lines. In fact, in 2008, New Hampshire Fish and Game staff recovered a banded loon after it collided with a power line in Stewartstown, causing a local power outage."

Northern Pass misrepresents the likely energy market and environmental impact of the project (CO2 reduction; reduction of dependence on natural gas use) and the project's role in addressing New England's reliability concerns. Northern Pass fails to discuss reliability threats posed by its project. Northern Pass misrepresents its ability to gain site control over its proposed route and the likely employment prospects of its project.

"Given the high concentration of migrating passerines, the overlap of flight elevations with proposed tower heights, and the location of this area within the White Mountain National Forest, we strongly urge that the Northern Pass EIS include studies of migration patterns over the proposed corridor at key locations, designed in consultation with experienced migration specialists. Potential locations might include the western slope of Kinsman Mountain and the Pemigewasset River valley, where migration tracks and the proposed route are likely to intersect, and possibly the Bog Pond basin, where extensive wetlands may provide an important stopover area in this mountainous landscape."

Comprehensive inventory of historic resources needed; setting and surrounding landscapes must be considered; consider all alternatives, including burial and no build; consider economic impacts on tourism.

Environmental impacts. Northern Pass's proposed new right of way "will result in the fragmentation of three intact forest blocks . . . Unfragmented forest blocks are considered to be very important features on the natural landscape . . ."